Oregon reasonable‑accommodation requirements

Coverage & definitions

Oregon’s disability accommodation duty, ORS 659A.112, applies to employers with six or more employees — below the federal ADA’s 15. Most other protections in ORS Chapter 659A reach employers of every size, so the six-employee floor is specific to disability and uniformed-service claims.

“Disability” is defined broadly as a physical or mental impairment that substantially limits one or more major life activities, and the law also covers perceived disabilities and a record of impairment. Since January 1, 2020, Oregon’s Employer Accommodation for Pregnancy Act (2019 HB 2341) has applied the same six-employee threshold to known limitations related to pregnancy, childbirth, or a related medical condition, including lactation.

Reasonable‑accommodation duties

Employers must offer reasonable accommodations for known disabilities unless doing so would cause undue hardship — significant difficulty or expense relative to the size and resources of the organization. Examples include physical modifications to the workplace, adjusted schedules, modified equipment, assistive technology, job restructuring, reassignment of non-essential tasks, or unpaid leave.

For pregnancy-related limitations, the statute lists accommodations that may include:

• Acquisition or modification of equipment or devices.
• More frequent or longer break periods or periodic rest.
• Assistance with manual labor.
• Modification of work schedules or job assignments.

Two prohibitions apply: an employer may not require an employee to take leave if another reasonable accommodation can be provided, and may not deny employment opportunities or take adverse action because an employee requested or used an accommodation.

Notice, documentation & the interactive process

Oregon imposes an affirmative written notice duty under the pregnancy accommodation law. Employers must post a written notice of employees’ rights in a conspicuous and accessible location, and must also deliver written notice directly at three points:

• To new employees at the time of hire.
• To existing employees (originally within 180 days of the law taking effect).
• To any employee within 10 days of being informed of that employee’s pregnancy.

The Bureau of Labor and Industries publishes a model notice.

On documentation, employers may request limited medical documentation to verify a disability-related need, but only what is relevant to the specific request, and it must be kept confidential. Oregon does not set a fixed response deadline; an oral or written request starts the interactive process, and BOLI expects a prompt, good-faith dialogue with clear records of requests, conversations, and decisions.

Enforcement & penalties

Complaints are filed with the Oregon Bureau of Labor & Industries (BOLI). Since the Workplace Fairness Act took effect on September 29, 2019, disability discrimination claims under ORS 659A.112 carry a five-year window — for both a BOLI complaint and a civil action — rather than the one-year limit that still applies to most other employment claims.

Remedies can include back pay, reinstatement, compensatory damages, and injunctive relief, and BOLI may order policy changes. The long limitations period makes record retention of accommodation files materially more important than in most states.

How Disclo simplifies Oregon accommodation compliance

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Practical tips for employers

• Post the pregnancy-rights notice and put it in your onboarding packet; diarize the 10-day written notice from the moment an employee tells you they are pregnant.
• Track headcount against the six-employee threshold, which applies to disability and pregnancy claims specifically.
• Keep accommodation files for at least five years — the limitations period is the longest of any state.
• Treat an oral request as a request; no form or legal language is needed to start the process.
• Request only documentation tied to the specific limitation, and keep it confidential.
• Never push an employee onto leave when another accommodation would work.

This guide is provided for general informational purposes only and does not constitute legal advice. Employment laws change frequently and vary by jurisdiction. Consult qualified employment counsel before acting on any information here. Last reviewed: September 2026.